Which statement best describes the relationship between an agency's interpretation of its own procedural rules and Chevron deference?

Which statement best describes the relationship between an agency's interpretation of its own procedural rules and Chevron deference?

• A. Chevron deference always applies to agency interpretations of procedures.
• B. Chevron deference generally applies to statutes, not to an agency's interpretation of its own procedural rules.
• C. Chevron deference never applies to agency interpretations of procedures.
• D. Chevron deference applies only when the agency's interpretation is adopted by Congress.

Answer: (B)

Chevron deference governs how courts treat an agency’s reading of statutes, not how they treat the agency’s own rules. It asks whether Congress left room for agency discretion in a statute and, if so, defers to the agency’s reasonable interpretation. When the issue is what a procedural rule means, Chevron isn’t the framework; instead, courts look to deference standards that apply to agency regulations—most commonly Auer deference, which defers to reasonable agency interpretations of its own regulations (subject to limits set by later cases). So the statement that Chevron deference generally applies to statutes, not to an agency’s interpretation of its own procedural rules, best captures the usual boundary between these doctrines. The other options misstate the relationship: Chevron is not the default for procedures, and interpretations of agency rules can receive other forms of deference under the right circumstances (and aren’t conditioned on Congress’s adoption).

Chevron deference governs how courts treat an agency’s reading of statutes, not how they treat the agency’s own rules. It asks whether Congress left room for agency discretion in a statute and, if so, defers to the agency’s reasonable interpretation. When the issue is what a procedural rule means, Chevron isn’t the framework; instead, courts look to deference standards that apply to agency regulations—most commonly Auer deference, which defers to reasonable agency interpretations of its own regulations (subject to limits set by later cases). So the statement that Chevron deference generally applies to statutes, not to an agency’s interpretation of its own procedural rules, best captures the usual boundary between these doctrines. The other options misstate the relationship: Chevron is not the default for procedures, and interpretations of agency rules can receive other forms of deference under the right circumstances (and aren’t conditioned on Congress’s adoption).